My name is Pat Kerrigan; I am Retail Education Coordinator for the Organic Consumers Association, which represents two million North American members and readers in safeguarding organic standards.

Coordinating OCA’s Going GMO-free Grocers contest and best practices online tool kit, I have learned that co-op and natural foods customers across the country are told by their grocers that if they want to be certain to avoid GMOs, they should look for the USDA organic seal.

The glaring exception to this industry-wide recommendation is the administration of GMO vaccines to organic livestock. The National Organic Program knows and has admitted that genetically engineered vaccines are being used; yet to date not one GMO vaccine has been submitted for review to the National Organic Standards Board as required by law.

Consumers pay a significant premium for the added value that they assign to organically produced livestock products. Allowing unapproved vaccines developed from excluded methods to be given to organic livestock is a serious violation of
the organic rules and a betrayal of the public’s trust in the integrity of organic.

Knowing that the organic meats and dairy products they purchase are coming from animals vaccinated with unapproved GMO vaccines seriously damages
consumers’ trust in these products, and in the organic seal itself.

GMO vaccines are inherently unpredictable and possibly dangerous. According to a review of the risks prepared for the NOSB’s own technical advisory panel:

”The non-pathogenic strain present in the vaccine may mutate or combine with other strains to become pathogenic after administration. With bacterial GMO vaccines (which are primarily administered via the mouth), there are concerns that the engineered bacteria may recombine with natural bacteria in the gastrointestinal tract…Shed DNA (in the animals feces and other secretions) could potentially infect other animals and spread the virus or bacteria…or recombine with naturally occurring viruses, forming altered virus strains with unpredictable characteristics.”

It’s time for the NOSB to assert its authority to review, regulate and when appropriate, prohibit genetically engineered vaccines. The NOSB should tell the NOP to enforce the law and get GMO vaccines, none of which have been reviewed or approved, out of organic!

And it’s time for the NOP to require that every vaccine used in organic be petitioned for review, so that the NOSB, with the help of a technical advisory panel, can determine which ones have been genetically engineered and, of those, which, if any, should be allowed in organic.

The work of the Livestock Committee is much appreciated and its recommendation should be passed and implemented by the NOP.

But please don’t stop there. What is really needed is a recommendation from the NOSB directing the NOP to inform the manufacturers of the approximately 73 registered animal vaccines that if they want their vaccines to continue to be used in organic, they must submit petitions to the NOSB seeking approval.

The problem of GMO vaccines illegally being used in organic cannot continue to be a game of hot potato between the NOP and NOSB. At some point the vaccine manufacturers have to be held accountable to the law.

Please be respectful of the decades of work that organic farmers, retailers, and other early pioneers have invested into developing the strong organic standards that organic consumers believe in and put their trust in, making organic the long-time food industry leader in sales growth, which are expect to top $40 billion this year.

I was surprised and alarmed to hear my twenty four year old stepdaughter and her boyfriend estimate that roughly half of their friends consider organic to be mainly a scam for companies to charge more money for foods.

I don’t know how many young people in America feel this way about organics, but I do know that revisions in the sunset law, unenforced requirements for outdoor access for livestock, especially chickens, and an ever-increasing number of synthetic ingredients being allowed in organic, including in baby food, are all eroding the foundation that the organic movement turned industry has been built on.

Consumer Reports stated these issues for why they recently downgraded the USDA organic seal in their Consumer Report’s Greener Choice report card, stating: "Given the concerns with standards and oversight over the last few years, CR no longer rates 'organic' as highly meaningful but meaningful.”

The cornerstone for organic agriculture is continually building the quality of the soil. The cornerstone for the NOSB’s work should be continually building stronger organic standards that improve the integrity of the organic seal, by reducing the number of synthetics allowed in organic, rather than increasing them.

Thank you for providing this public forum and your consideration of my comments.

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